The Weekly Law Reports
[2007] 3 WLR 354
House of Lords
Sempra Metals Ltd (formerly Metallgesellschaft Ltd) v Inland Revenue Commissioners and another
[2007] UKHL 34
2006 Nov 1,
2;
2007 May 16;
July 18
2007 May 16;
July 18
Lord Hope of Craighead, Lord Nicholls of Birkenhead, Lord Scott of Foscote, Lord Walker of Gestingthorpe and Lord Mance
Restitution
— Unjust enrichment
— Money had and received
— Recovery of interest
— Dividends paid by UK subsidiary to non-resident parent subjected to premature tax liability
— Decision of European court that payments unlawful for restricting freedom of establishment
— National court's computation of compensation for interest accruing during premature payment period
— Whether simple or compound interest payable